Corporate TaxArticle·23 July 2026
Management fees is not FTS
By J the App
Executive Summary
The Income Tax Appellate Tribunal, Mumbai Bench held that management and business support services rendered to the Indian subsidiary did not 'make available' any technical knowledge, skill, know-how or processes.
Consequently, the consideration received could not be taxed as Fees for Technical Services under Article 12(4)(b) of the India–Singapore Double Taxation Avoidance Agreement (DTAA).
Domain | Corporate Tax | International Tax
Background
The assessee, a tax re...
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